Background Illustrations for · 19/04/2016 · electronic reporting and sharing operational experience. •FFD-related events reports. Based on the significance of the event, the

Background Illustrationsfor

PUBLIC MEETING REGARDING FITNESS-FOR-DUTY PROGRAM EFFECTIVENESS, REQUIREMENTS, GUIDANCE, AND OPTIONS TO

MINIMIZE FUTURE POLICY CHANGES

April 19, 2016

The information in this presentation and the discussions during the public meeting are provided as a public service and solely for informational purposes and is not, nor should be deemed as, an official NRC position, opinion or guidance, or "a written interpretation by the General Counsel" under 10 CFR 26.7, on any matter to which the information may relate. The opinions, representations, positions, interpretations, guidance or recommendations which may be expressed by the staff in this enclosure or during the public meeting are solely the staff's and do not necessarily represent the same for the NRC. Accordingly, the fact that the information was obtained through the staff will not have a precedential effect in any legal or regulatory proceeding.

Disclaimer

Slide 2

Initializations & Acronyms

Part 26 10 CFR Part 26§ 26.717 10 CFR 26.717 or Section 26.717FFD Fitness for DutyC/V Contractor/VendorLE Licensee EmployeeBOP Behavioral Observation ProgramAA Access Authorization

Slide 3

How NRC staff obtains its FFD Performance Information

Licensees and other entities subject to Part 26 are required to report the following FFD performance information to the NRC:

• Annual drug and alcohol testing program test results, subversion attempts, and program information (§ 26.717). To report this information, the industry uses two electronic forms located at http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/submit-ffd-reports.html. This staff commends the industry for electronic reporting and sharing operational experience.

• FFD-related events reports. Based on the significance of the event, the licensee will report the information to the NRC within 24 hours or 30 days of the event (§ 26.719).

The NRC staff also obtains drug and alcohol testing information from NRC inspectors, Federal partners, and drug testing laboratories.

Slide 4Staff presentation material. Please see “Disclaimer” Slide 2.

http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/submit-ffd-reports.html

Every year the NRC staff publishes an annual summary report describing FFD performance in the commercial nuclear industry. These reports can be viewed: http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/performance-reports.html.

The staff also uses the information to risk-inform and performance-base policy and guidance and the NRC’s inspection program. For example:

Site-specific pre-access testing rates may identify regions in the U.S. where substance abuse is prevalent

For-cause and post-event testing rates could indicate how well individuals at a site follow the licensee’s FFD program

Industry-wide drug testing information is shared with Federal partners to inform the National strategy on substance use and abuse.


What the NRC staff does with FFD Performance Information

http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/performance-reports.html

Overall Industry Performance, 2014

75 FFD programs

166,590 Individuals drug & alcohol tested (up 3% from 2013)

1,133 Individuals that tested positive for a drug, alcohol, or refused a test

67% identified at pre-access testing19% identified at random testing

0.68% Industry overall positive rate up from 0.62% in 20130.23% LE positive rate down from 0.25% in 20130.88% C/V positive rate up from 0.81% in 2013

0.34% Industry random positive rate up from 0.31% in 20130.14% LE positive rate same as in 20130.62% C/V positive rate up from 0.57% in 2013


90% of positives and testing refusals are from contractor/vendors

Positives and testing refusals vary by employment type and test category

Pre-Access Random For-Cause

C/Vs 73% 16% 6%

LEs 23% 45% 20%


Results by Test Type and Employment Category, 2014


Positive Rates by Employment Category and Test Type

Contractor/Vendors(115,662 tested, 1,015 individuals positive)

Licensee Employees (50,928 tested, 118 individuals positive)


Results by Employment Type, 2014

Detection Trends – NRC Testing Panel


FFD Performance Trends

Multi-year trends:• Amphetamine and

methamphetamine (increased detection)

• Subversion attempts(high prevalence)

Year Amphetamines & Methamphetamines

Percentageof Total Positives

Subversion Attempts

Percentageof Violations

2012 6.15% 15.8%2013 8.93% 14.7%2014 10.6% 16.5%

Multi-substance positives (2012−2014)• 34-48 individuals per year tested positive for more than one substance• 83-93% of these individuals tested positive for amphetamines,

methamphetamines, and/or cocaine

24-hour reportable events (§26.719) to NRC (2012−2015)• Two to six individuals in the “critical group” (i.e., operators, supervisors)

test positive each year for amphetamines or cocaine


Multi-Substance Positive Results, 2014

48 of the 1,133 individuals with a drug and/or alcohol testing violation in 2014 tested positive for more than one substance (47 of these 48 individuals were contractor/vendors)18 of 75 sites with an FFD program reported at least one multi-substance positive result in 201423 of 48 individuals that tested positive for more than one substance worked at a subpart K construction site


24-Hour Reportable Events (§ 26.719)Amphetamines and Cocaine Positives

2015– Reactor operators (1 cocaine of 7 reportable events)– Supervisors (1 amphetamine of 16 reportable events)

2014– Reactor operators (1 cocaine of 9 reports events)– Supervisors (2 cocaine of 27 reportable events)

2013– Reactor operators (1 cocaine of 12 reportable events)– Supervisors (1 cocaine of 17 reportable events)

2012– Reactor operators (0 of 6 reportable events)– Supervisors (6 cocaine of 25 reportable events)


Heroin Test Results, 2010-2015

2015 4 positive results (3 sites) [not complete, still collecting data]2 Pre-Access Point Beach: C/V; Outage worker; HR/RP; Reinstatement (6-30 days); 6-AM

Waterford: C/V; Maint.(general facility); Initial Authorization; 6-AM, codeine, & morphine

2 Random Millstone: C/V; Outage worker; Maint.(general facility); 6-AM, cocaine, & morphineWaterford: Licensee employee; Engineering; 6-AM, codeine, & morphine

2014 2 positive results (2 sites)Pre-Access Dresden: C/V; Maintenance (Craft); Initial Authorization; 6-AMPre-Access Millstone: C/V; Maintenance (Craft); 6-AM

2013 1 positive resultPre-Access V.C. Summer 2&3: C/V, Maintenance (Craft); 6-AM & morphine

2012 None

2011 2 positive results (2 sites)Post-Event Surry: CV, Maintenance (Craft); 6-AMPost-Event Waterford: C/V, Security; 6-AM & morphine

2010 1 positive resultPre-Access Palo Verde; Maintenance (Craft); Initial Authorization; 6-AM & morphine;

subversion on initial specimen out-of-temperature range


Subversion Trends, 2012-2014

Subversion attempt is any act or attempted act to subvert the testing process (e.g., refusing to provide a specimen, providing or attempting to provide a substituted or adulterated specimen).

Results in a permeant denial of authorization (§26.75)

Subversion Attempts2012 177 of 1,114 violations = 15.8% subversions

2013 148 of 1,007 violations = 14.7% subversions

2014 187 of 1,133 violations = 16.5% subversions

In 201472% of subversion attempts occur at pre-access testing

96% of subversion attempts were made by C/Vs


How subversions were identified, 2014

187 individuals were identified as subverting the testing process. 120 refused to provide a 1st or 2nd specimen for testing (64%)

4 were identified by validity testing (1 adulterated & 3 substituted)

118 had an out-of-temperature condition (63%)

63 tested positive for a drug (i.e., observed 2nd specimen collection, 34%)


Effectiveness of Lower Cutoff Levels for Alcohol Testing, 2014

Pre-Access Random For Cause Post-Event Followup Grand Total0.04 or greater 78 32 41 1 17 1690.03 and in work status at least 1 hr 21 12 3 1 4 410.02 and in work status at least 2 hrs 15 20 2 37Grand Total 114 64 44 2 23 247


Where testing was conducted and where positivity was identified, 2014


NRC Fitness for Duty Program Staff

U.S. Nuclear Regulatory CommissionOffice of Nuclear Security and Incident ResponseDivision of Security Policy, Security Programs and Support Branch

Paul Harris, Senior Program [email protected] (301-287-9294)

Will Smith, Security Specialist [email protected] (301-287-3541)

Brian Zaleski, FFD Program [email protected] (301-287-0638)


mailto:[email protected]



Documents

Background Illustrations for · 19/04/2016 · electronic reporting and sharing operational experience. •FFD-related events reports. Based on the significance of the event, the